- 17 - invoices, receipts, and other documents, which Mrs. McKeever placed in a manila envelope each month. At the end of each taxable year, Mrs. McKeever compiled annual expense journals from the stored documents. Petitioners also kept pedigrees and show records for their horses. Starting in about 1993, Mr. McKeever began studying bloodlines and pedigrees. Petitioners did not keep heat and health records for their horses, except for copies of veterinary bills and notations made on a small calendar kept in their barn. Petitioners did not prepare written profit and loss projections for the taxable years 1991, 1992, and 1993 concerning their horse activity, or any of their other activities, nor have they prepared any such projections for taxable years commencing after 1993 through the trial in this case.9 9In 1998, after the petition in this case had been filed, petitioners consulted an accountant with experience in the horse industry, Patrick J. Hurley. At Mr. Hurley’s suggestion, petitioners began using a computerized record keeping system. Mr. Hurley provided petitioners with a sample “Summary of Operations” for a horse business and advised them to prepare a similar document. Petitioners prepared a summary of operations for their horse activity for the years 1988 through 1998, which they refer to as a business plan. The document summarizes various facts related to the horse activity and indicates in very general terms how petitioners plan to improve the profitability of the activity. The document does not indicate what level of income would be required to achieve profitability or to what extent expenses might be reduced. Although petitioners maintained detailed expense records, the summary of operations does not analyze any of the past expenses to determine whether any adjustments to those expenses could improve profitability.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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